In last month’s article we talked by chemicals in the workplace and the upcoming changes to the OSHA Hazard Communication Standard. Good planning is essential to chemical handling. That is why any organization that deals with hazardous chemicals and does not allow workers to assist in handling a spill must have an Emergency Action Plan (EAP) in place should an incident occur with hazardous chemicals.

While you can’t always prevent chemical spills and other emergencies like fire, explosions, earthquakes, hurricanes and floods; you can prepare for them. In fact, you have to prepare for them. The OSHA Means of Egress standard(1910, Subpart E) requires employers to take steps to prepare workers to evacuate safely in the event of an emergency. Establishing an EAP is key to OSHA compliance. This OSHA standard covers just about all workplaces. The only companies not covered are those that have an in-house fire brigade in which every worker is trained and equipped to fight fires, and consequently, no one is expected to evacuate.

The EAP must be in writing, kept in the workplace and be available for employees to review. The only exception to this rule is that a company can communicate the EAP to workers orally if they have 10 or fewer employees.

The following is a list of what elements which must be included in an EAP:

Procedures for employees with disabilities and require help evacuating;

Procedures to be followed by employees who remain behind to operate critical plant operations before they evacuate;

Procedures to account for all employees after evacuation;

Procedures to be followed by employees performing rescue or medical duties; and

The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.

Additionally, as part of the EAP, you must maintain an employee alarm system that uses a distinctive signal for each purpose. You must also designate and train employees to assist other employees to evacuate safely and in an orderly way.

The OSHA EAP regulation also includes training requirements. Employees designated to use firefighting equipment under the EAP must be trained in the appropriate use of the equipment upon initial assignment of that responsibility and at least once a year after that.

Keep in mind that emergency follow-up is essential. If an incident results in a workplace fatality or if three or more persons are hospitalized, it must be reported to OSHA within 8 hours. If you have a significant chemical spill, the National Response Center must be notified. The Department of Environmental Protection regulates chemical releases to the environment.

Emergency planning is an important part of a company’s risk management and loss prevention program. Remember that there is no such thing as “it can’t happen here.” To get more information on OSHA’s EAP requirements visit their website at www.osha.gov.

Michael L. Miozza has directed the environmental, health and safety systems for several major corporations and has over twenty years of experience in the area of regulatory compliance.

He is nationally recognized as a Certified Safety Professional and a Certified Professional Environmental Auditor. Michael is the founder of Health and Safety Solutions, Inc. a provider of health, safety and environmental compliance solutions. For more information, please visit www.health-safetysolutions.com or call toll free at (855) 785-8562.

The recent downsizing of many companies due to the economic changes has often placed the management of occupational health, safety and environmental programs on human resource professionals or business owners, who lack the benefit of experience or education in this field.

As the human resource person or business owner you now have the responsibility of managing your company’s safety and environmental programs. Congratulations! But what do you do and where do you start? Safety and protecting the environment is a full time job considering the numerous safety and environmental related areas you need to be aware of: safety procedures, TIER II reporting, worker training, OSHA and EPA standards, reasonable accommodations, SPCC plans, workers’ compensation, accident investigations, GHS, recordkeeping, storm water permits, return-to-work Issues, safety committees…various forms…and the list goes on and on.

For this month’s article, let’s start with GHS. New changes to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard are bringing the United States into alignment with GHS. GHS is an acronym for The Globally Harmonized System of Classification and Labelling of Chemicals. The GHS is a system for standardizing and harmonizing the classification and labelling of chemicals. GHS affects hazard communication in the workplace. In 2003, the United Nations adopted this system and OSHA made it the law of the land on May 26, 2012.

This means if your employees work with hazardous chemicals, then you, the employer, are required by this law to train them to the updated OSHA standard by December 1, 2013. The new standard requires that workers be trained on the new label elements and the new safety data sheet format. Full compliance with GHS will begin in 2015.

What can I do as an employer to be prepared for this significant transition? You have just over 6 short months until your employees must be trained. Start compiling training materials now to ensure your team will be better prepared and ready to train your current and future employees on the new pictogram definitions, signal words, hazard classification categories and hazard and precaution statements, along with the new SDS format. Keeping up-to-date inventories of all hazardous chemicals and the status of the MSDS/SDS will be essential. While the GHS transition may seem overwhelming and taxing to an already full workload, OSHA has provided enough time for companies to come into compliance with the updated regulation. To get more information on this updated OSHA standard visit their website at www.osha.gov.

Michael L. Miozza has directed the environmental, health and safety systems for several major corporations and has over twenty years of experience in the area of regulatory compliance.

He is nationally recognized as a Certified Safety Professional and a Certified Professional Environmental Auditor. Michael is the founder of Health and Safety Solutions, Inc. a provider of health, safety and environmental compliance solutions. For more information, please visit www.health-safetysolutions.com or call toll free at (855) 785-8562.